Separate Consolidated Federal Income Tax Liability definition

Separate Consolidated Federal Income Tax Liability means, for any Group and any taxable year or portion thereof during which it is included in the Consolidated Returns or any Prior Period Consolidated Return, the U.S. federal income Tax liability which such Group would have incurred if such Group, on a stand-alone basis, had been an affiliated group eligible to file a consolidated return for such taxable year or any portion thereof and had filed such a return for such period, computed without regard to AMT.
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Separate Consolidated Federal Income Tax Liability means, for any Company and its Subsidiaries and for any taxable period or portion thereof during which such Company and its Subsidiaries is included in the Consolidated Return or any Prior Period Consolidated Return, the U.S. federal income Tax liability that such Company and its Subsidiaries would have incurred if such Company and its Subsidiaries, on a stand-alone basis, had been an affiliated group eligible to file a consolidated return for such taxable period or portion thereof for U.S. federal income tax purposes, computed without regard to AMT, provided that (i) the Industrial Chemicals Business conducted directly by GCC prior to the Industrial Contribution (including, without limitation, GCC's interest in GCSAP) shall be treated as a GCG Subsidiary for purposes of this definition, and shall not be taken into account in determining the Separate Consolidated Federal Income Tax Liability of GenTek and the GenTek Subsidiaries and (ii) 50 percent of each "intercompany item" that any of GenTek, GCG or their respective Subsidiaries is required to take into account immediately prior to the Spinoff pursuant to Treasury Regulations section 1.1502-13 shall be taken into account in determining the Separate Consolidated Federal Income Tax Liability of GenTek and the GenTek Subsidiaries, and the remaining 50 percent of each such item shall be taken into account in determining the Separate Consolidated Federal Income Tax Liability of GCG and the GCG Subsidiaries.
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Separate Consolidated Federal Income Tax Liability means, with respect to any year or portion thereof, the Tax liability which a Group would have incurred if such Group, on a stand alone basis, had been an affiliated group eligible to file a consolidated return for any portion of such taxable year during which it is included in the Consolidated Return or any Prior Period Consolidated Return and had filed a return for such period, computed without regard to AMT; provided, however, that in computing the Tax liability of the ITT Group, any Tax Item attributable to ITT and arising prior to the Distribution Date (determined as if there were a closing of the books as of such date) shall not be taken into account and shall be treated as a Tax Item of the Destinations Group; provided further that any credits of WD and its subsidiaries shall be treated as utilized at the earlier of the time such credits are utilized (a) in the Consolidated Return or any Prior Period Consolidated Return or (b) in the computation of the Separate Consolidated Federal Income Tax Liability of the ITT Group. "Spin-Off Tax Payee" shall have the meaning assigned to such term in Section 10(b)(ii) of this Agreement. "Spin-Off Tax Payor" shall have the meaning assigned to such term in Section 10(b)(ii) of this Agreement. 4 76 "Tax" or "Taxes" shall mean all forms of taxation, whenever created or imposed, and whether of the United States or elsewhere, and whether imposed by a local, municipal, governmental, state, foreign, federal or other body, and without limiting the generality of the foregoing, shall include income, sales, use, ad valorem, gross receipts, license, value added, franchise, transfer, recording, withholding, payroll, wage withholding, employment, excise, occupation, unemployment insurance, social security, business license, business organization stamp, environmental, premium and property taxes, together with any related interest, penalties and additions to any such tax, or additional amounts imposed by any Taxing Authority (domestic or foreign) upon the Destinations Group, the ITT Group, the ESI Group or any of their respective members or divisions or branches or affiliates. "Tax Administrator" shall mean Allax X. Xxxxx, xxe Director of Taxes of Destinations, or such other person as Destinations shall appoint with the consent of each of ITT and ESI, which consent shall not be unreasonably withheld or delayed. "Taxing Authority" shall mean any governmental or quasi-governmental body exercising any Taxing authority or Tax regula...
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Examples of Separate Consolidated Federal Income Tax Liability in a sentence

  • For purposes of this paragraph 5(a), the computation of Separate Consolidated Federal Income Tax Liability shall take into account the benefit of any net capital loss, net operating loss, credit or deduction of the ITT Destinations Group or the ITT Hartford Group if the Federal Tax Administrator reasonably determines that such item will produce a benefit in the Consolidated Return.

Related to Separate Consolidated Federal Income Tax Liability

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Income Tax Return means any Tax Return relating to Income Taxes.

  • Non-Income Tax Return means any Tax Return relating to any Tax other than an Income Tax.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the Hypothetical Federal Tax Liability for such Taxable Year, plus the Hypothetical Other Tax Liability for such Taxable Year.

  • Consolidated Income Tax Expense for any period means the provision for taxes of the Issuer and the Restricted Subsidiaries, determined on a consolidated basis in accordance with GAAP.

  • Taxable income means, in the case of an individual, federal adjusted gross income determined without regard to 26 U.S.C. § 168(k) and:

  • Consolidated Income Taxes means, with respect to any Person for any period, taxes imposed upon such Person or other payments required to be made by such Person by any governmental authority which taxes or other payments are calculated by reference to the income or profits of such Person or such Person and its Restricted Subsidiaries (to the extent such income or profits were included in computing Consolidated Net Income for such period), regardless of whether such taxes or payments are required to be remitted to any governmental authority.

  • Income Tax Expense means, with respect to the Borrowers, for any period, the aggregate, without duplication, of all Taxes on the income of such Person for such period, whether current or deferred, determined on a Modified Consolidated Basis.

  • Consolidated Return means a Tax Return filed with respect to Federal Income Taxes for the Consolidated Group.

  • Tax Liability means the total taxes due to a municipal corporation for the taxable year, after allowing any credit to which the taxpayer is entitled, and after applying any estimated tax payment, withholding payment, or credit from another taxable year.

  • Net Taxable Income has the meaning set forth in Section 4.01(b)(i).

  • Federal Income Tax means any Tax imposed by Subtitle A of the Code, and any interest, penalties, additions to tax, or additional amounts in respect of the foregoing.

  • Assumed Tax Liability means, with respect to any Member, an amount equal to the excess of (i) the product of (A) the Distribution Tax Rate multiplied by (B) the estimated or actual cumulative taxable income or gain of the Company, as determined for federal income tax purposes, allocated to such Member (or its predecessor) for full or partial Fiscal Years commencing on or after January 1, 2021, less prior losses of the Company allocated to such Member (or its predecessor) for full or partial Fiscal Years commencing on or after January 1, 2021, in each case, as determined by the Manager and to the extent such prior losses are available to reduce such income over (ii) the cumulative Tax Distributions made to such Member after the closing date of the IPO pursuant to Sections 4.01(b)(i), 4.01(b)(ii) and 4.01(b)(iii) and, if applicable with respect to such Fiscal Year, pursuant to Section 4.1(a) of the Previous LLC Agreement; provided that, in the case of the Corporation, such Assumed Tax Liability (x) shall be computed without regard to any increases to the tax basis of the Company’s property pursuant to Sections 734(b) or 743(b) of the Code and (y) to the extent permitted under the Credit Agreements and applicable Law, shall in no event be less than an amount that will enable the Corporation to meet both its tax obligations and its obligations pursuant to the Tax Receivable Agreement for the relevant Taxable Year; provided further that, in the case of each Member, and for the avoidance of doubt, such Assumed Tax Liability shall take into account any Code Section 704(c) allocations (including “reverse” 704(c) allocations) to the Member.

  • Income Tax means any federal, state, local, or foreign income tax, including any interest, penalty, or addition thereto, whether disputed or not.

  • Net Tax Benefit has the meaning set forth in Section 3.1(b) of this Agreement.

  • Non-Income Tax means any Tax other than an Income Tax.

  • Income Tax Act means the Income Tax Act (Canada), as amended from time to time;

  • Consolidated Net Income (Loss) of any Person means, for any period, the Consolidated net income (or loss) of such Person and its Subsidiaries for such period on a Consolidated basis as determined in accordance with GAAP, adjusted, to the extent included in calculating such net income (or loss), by excluding, without duplication, (i) all extraordinary gains or losses (exclusive of all fees and expenses relating thereto), (ii) the portion of net income (or loss) of such Person and its Subsidiaries on a Consolidated basis allocable to minority interests in unconsolidated Persons to the extent that cash dividends or distributions have not actually been received by such Person or one of its Subsidiaries, (iii) net income (or loss) of any Person combined with such Person or any of its Subsidiaries on a “pooling of interests” basis attributable to any period prior to the date of combination, (iv) any gain or loss, net of taxes, realized upon the termination of any employee pension benefit plan, (v) net gains (or losses) (except for all fees and expenses relating thereto) in respect of dispositions of assets other than in the ordinary course of business, (vi) the net income of any Subsidiary to the extent that the declaration of dividends or similar distributions by that Subsidiary of that income is not at the time permitted, directly or indirectly, by operation of the terms of its charter or any agreement, instrument, judgment, decree, order, statute, rule or governmental regulation applicable to that Subsidiary or its stockholders, (vii) any gain arising from the acquisition of any securities, or the extinguishment, under GAAP, of any Indebtedness of such Person, (viii) transaction costs charged in connection with the Refinancing, or (ix) amortization of intangible assets of such Person and its Subsidiaries on a consolidated basis under GAAP.

  • Adjusted Consolidated Net Income means, for any period, the aggregate net income (or loss) of the Company and its Restricted Subsidiaries for such period determined in conformity with GAAP; provided that the following items shall be excluded in computing Adjusted Consolidated Net Income (without duplication): (i) the net income of any Person that is not a Restricted Subsidiary, except to the extent of the amount of dividends or other distributions actually paid to the Company or any of its Restricted Subsidiaries by such Person during such period; (ii) solely for the purposes of calculating the amount of Restricted Payments that may be made pursuant to clause (C) of the first paragraph of Section 4.04 (and in such case, except to the extent includable pursuant to clause (i) above), the net income (or loss) of any Person accrued prior to the date it becomes a Restricted Subsidiary or is merged into or consolidated with the Company or any of its Restricted Subsidiaries or all or substantially all of the property and assets of such Person are acquired by the Company or any of its Restricted Subsidiaries; (iii) the net income of any Restricted Subsidiary to the extent that the declaration or payment of dividends or similar distributions by such Restricted Subsidiary of such net income is not at the time permitted by the operation of the terms of its charter or any agreement, instrument, judgment, decree, order, statute, rule or governmental regulation applicable to such Restricted Subsidiary; (iv) any gains or losses (on an after-tax basis) attributable to Asset Sales; (v) except for purposes of calculating , the amount of Restricted Payments that may be made pursuant to clause (C) of the first paragraph of Section 4.04, any amount paid or accrued as dividends on Preferred Stock of the Company or any Restricted Subsidiary owned by Persons other than the Company and any of its Restricted Subsidiaries; and (vi) all extraordinary gains and extraordinary losses (on an after-tax basis).

  • Consolidated Liabilities means, as at any date of determination, all liabilities of the Borrower and its Subsidiaries as of such date classified as liabilities in accordance with GAAP and determined on a Consolidated basis.

  • Pre-Tax Income means income, as determined by GAAP, prior to deduction of the Bonus Pool (as hereinafter defined) and income taxes, and if applicable, after the deduction of any bonus pool of a future officer bonus plan adopted by the Company relating to an applicable Award Year and adjustments approved by the Board as described herein.

  • Income Taxes means any Tax which is based upon, measured by, or calculated with respect to (i) net income or profits (including, but not limited to, any capital gains, gross receipts, value added or minimum Tax) or (ii) multiple bases (including, but not limited to, corporate franchise, doing business or occupation Taxes) if one or more of the bases upon which such Tax may be based, by which it may be measured, or with respect to which it may be calculated is described in clause (i) of this sentence.